Transfer pricing officer (TPO) erred by considering ...

Company's Transfer Pricing Adjustment Should Only Consider Associated Enterprises' Transactions.

Case Laws Income Tax

August 24, 2024

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to Income Tax Appellate Tribunal (ITAT) and Dispute Resolution Panel (DRP) directions. TP adjustment should only consider transactions with associated enterprises (AEs), as per transfer pricing regulations and Chapter X of the Income Tax Act. ITAT directed assessing officer (AO)/TPO to rectify by considering only AE transactions for TP adjustment computation, without circumventing ITAT and DRP directions. Assessee's appeal allowed for statistical purposes.

View Source

← Previous Next →

Transfer pricing officer (TPO) erred by considering ...

Company's Transfer Pricing Adjustment Should Only Consider Associated Enterprises' Transactions.

Case Laws Income Tax

August 24, 2024

You may also like:

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

Transfer pricing adjustment – When the indent/commission transaction with the associated enterprises is to be benchmarked, the same should be done with indent/...

TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment...

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to...

Transfer pricing adjustment - international transaction relating to acquisition of intangible assets by assessee from its associated enterprise - All the additions...

Transfer pricing adjustments - associated enterprise - the transactions between the assessee [ IJMII Integrated Township Development Co. Pvt. Ltd] and IJMII do not fall...

TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

Transfer pricing adjustment – export to associated enterprises of spares and components required for the purpose of servicing of vehicles sold by assessee - the...

TP Adjustment - As per the provisions of aforesaid Rule, the ‘other method’ shall be the method which takes into account the price which has been or would have been...

Transfer pricing adjustment - arm‘s length pricing of international transactions - Advertising / Marketing and Promotion Expenses - international transaction - Domestic...

TP adjustment - onsite development and project coordination fee’ - Associated enterprise can be considered as a tested party, in the present case. Accordingly, we direct...

TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should...

For the purpose of transfer pricing adjustment, the transaction of the assessee with Associated Enterprise outside the country alone has to be taken into consideration....

Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

Quick Updates: